Former leaders of a New York-based NGO plead guilty to conspiracy to bribe elected Marshall Islands officials GRANDPA

Two Marshallese nationals today pleaded guilty to conspiring to pay bribes to elected officials of the Republic of the Marshall Islands (RMI) in exchange for passing certain legislation.

According to court documents, Cary Yan, 50, and Gina Zhou, 34, the heads of a New York-based non-governmental organization (NGO), conspired with others from 2016 until at least August 2020 using a multi-year bribery scheme. Yan and Zhou offered and paid tens of thousands of dollars in bribes to elected RMI officials – including, among others, members of the RMI Legislature – in exchange for supporting legislation to create a semi-autonomous region within the RMI called the Rongelap Atoll Special Administrative Region (RASAR). , which would benefit the business interests of Yan, Zhou and their associates. Yan and Zhou conducted the bribery and money laundering scheme using the New York NGO, including physically using their Manhattan headquarters to meet and communicate with RMI officials.

In November 2020, Thai authorities arrested Yan and Zhou in Thailand at the request of the United States under the US-Thailand extradition treaty, and following a court hearing, the Thai government extradited Yan and Zhou to the United States on September 2.

Yan and Zhou each pleaded guilty to one count of conspiracy to violate the anti-corruption provisions of the Foreign Corrupt Practices Act (FCPA). They each face a maximum sentence of five years in prison. A judgment date has not yet been set. A federal district court judge will determine the sentence after considering US sentencing guidelines and other legal factors.

Assistant Attorney General Kenneth A. Polite, Jr. of the Justice Department’s Criminal Division, US Attorney Damian Williams for the Southern District of New York, and Assistant Acting Director Michael J. Driscoll of the FBI’s New York Field Office made the announcement.

The FBI investigated the case. The Royal Thai Government, the United States Embassy in Bangkok and the Department of Justice’s International Affairs Office provided significant assistance in arresting and extraditing the accused.

Deputy Chief Gerald M. Moody Jr. and Trial Attorney Anthony Scarpelli of the Criminal Division’s Fraud Division and Assistant US Attorneys Hagan Scotten, Lara Pomerantz and Derek Wikstrom for the Southern District of New York are prosecuting the case.

The Fraud Division is responsible for investigating and prosecuting FCPA matters. For more information on the Department of Justice’s FCPA enforcement efforts, visit